Who is exempt from Medicaid work requirements?

Most of the people asked to prove 80 hours a month will meet the rule by working, volunteering, or going to school. But a lot of people shouldn't be asked at all. A mom with a toddler, a man six weeks out of jail, someone in cancer treatment: the federal rule leaves each of them out. The catch is that your state has to know that about you, and its records don't always show it.

This page walks through every group the federal rule leaves out, the extra hardship exceptions some states offer, and how to make sure your state gets it right. (For the basics of the 80-hour rule itself, start with our guide to Medicaid work requirements and volunteering.) This page can't tell you whether you qualify. Only your state can decide that.

Two kinds of exemption: excluded and deemed compliant

People say "exempt" for two different things in the rule. The difference matters.

• Excluded (CMS calls this a "specified excluded individual"). The 80-hour rule doesn't apply to you right now. CMS says "community engagement is not a condition of eligibility" for these groups. Your state shouldn't check your hours at all.
• Deemed compliant (CMS calls these "exceptions"). The rule does apply to you, but your state must count certain months as met because of what was going on that month. It only covers those months.

Here's how that plays out. Say your child turns 14 in June, your renewal is in September, and your state looks back over the six months since your last check. You were excluded as a parent through June. At renewal, you're no longer excluded, but your state must count April, May, and June as met, because you were excluded for part or all of those months. After that, you have to meet the rule going forward.

Who is excluded from Medicaid work requirements

These are the groups listed in the 2025 budget law and in CMS's interim final rule on Medicaid community engagement at 42 CFR 435.554. Each one is its own path. You only need one.

Parents, guardians, caretakers, and family caregivers

A dependent child means a child 13 or under. A disabled individual means anyone who meets the Americans with Disabilities Act definition of disability. They don't have to be on Medicaid or any other program.

• Parents count if they give some care to the child or disabled person.
• Guardians are appointed by a court. Your state will ask for the court order.
• Caretaker relatives live with the child or disabled person and take main responsibility for their care. Grandparents, aunts, uncles, older siblings, cousins, and step-relatives all count.
• Family caregivers can be relatives or not. If you live with the person, or you're related to them, you need to give care "on a regular basis" that's "not solely incidental." If you don't live with them and aren't related, you need to give at least 80 hours of care a month.

More than one adult in the same home can qualify. And if you care for a non-relative you don't live with for fewer than 80 hours, CMS says those hours count as unpaid work toward your 80. Your state can't refuse the exemption just because you won't name the disabled person you care for.

Medically frail or special medical needs

This is the broadest exemption and the hardest to prove. CMS's definition has two parts. First, your "physical, mental, or other behavioral health condition significantly impairs" your ability to meet the rule. Second, you're someone who:

• is blind or disabled under Social Security's definition,
• has a substance use disorder (unless you've been in stable recovery for 5 years or more),
• has a disabling mental disorder,
• has a physical, intellectual, or developmental disability that makes one or more daily activities (like bathing, dressing, or eating) much harder, or
• has a serious or complex medical condition. CMS lists traits like life threatening, causing significant pain, needing frequent monitoring, or needing care from several specialists.

Each state must keep a list of conditions that qualify. If your condition isn't on it, the state must still let you ask to be considered. And your state can't turn you down just because your claims records don't show the condition yet.

About self-attesting. Until January 1, 2028, your state may accept your own signed statement, under penalty of perjury, when its records can't confirm you're medically frail. Starting January 1, 2028, a state can accept that kind of statement only once while you stay enrolled. At your next renewal, it must confirm your status from its own records or from documents, like a note from your provider. States must recheck medical frailty at least every 12 months.

Veterans with a total disability rating

You need a VA rating of 100 percent, either temporary or permanent. CMS says veterans paid at the 100 percent rate because they can't work (called TDIU) also count, even if their combined rating is lower. You can get your rating letter from VA.gov. Temporary ratings get rechecked at least every 12 months. Permanent ones don't get rechecked.

SNAP and TANF

If your household gets SNAP and you are subject to a SNAP work rule, you're excluded from Medicaid's rule. Your state doesn't need to confirm you're actually meeting the SNAP rule. But if SNAP has exempted you from its work rules, that doesn't carry over to Medicaid. You'd need a different exemption. Our guide to SNAP work requirement exemptions explains SNAP's side. For TANF, you must be meeting your state's TANF work rules, and your Medicaid office should get that from the TANF office, not from you.

The other groups

• Former foster youth. Your state checks this from your application. It doesn't recheck until you turn 26.
• American Indians and Alaska Natives. This uses Medicaid's existing definition of "Indian," which includes Urban Indians, California Indians, and people found eligible for Indian Health Service care. Once verified, your state won't recheck it.
• Drug or alcohol treatment. The program must be run by a nonprofit or a public community mental health center. Your state may set a minimum amount of participation.
• Jail or prison. Being in custody now excludes you. Being released recently is covered below.
• Pregnant or postpartum. Your state must accept your word that you're pregnant unless it has information that doesn't match. Postpartum coverage lasts at least 60 days after pregnancy ends (through the end of that month), and 12 months in states that chose the longer option. As of May 2026, CMS says 48 states and DC had.

Who is deemed compliant

Your state must count a month as met if, for part or all of that month, you were:

• under 19,
• on Medicare (Part A or Part B),
• in one of Medicaid's other required coverage groups, or
• in one of the excluded groups above.

It must also count a month as met if you were in jail or prison at any point in the 3 months before that month. CMS's example: someone released March 15 who applies June 1 gets May counted as met.

Optional short-term hardship exceptions

States can choose to offer these. Some will. Some won't. Our state-by-state table shows what we've confirmed for each state. Where a state offers them, it counts a month as met if:

1. You were in the hospital or a similar facility, like a nursing facility or inpatient psychiatric care, or got outpatient care that kept you out of one. You or someone acting for you has to ask.
2. You live in a county with a disaster or emergency declared by the President. This is automatic.
3. You live in a county with high unemployment, at least 8 percent or 1.5 times the national rate, whichever is lower, and CMS has approved your state's request. This is automatic too.
4. You or your dependent had to travel outside your community for a long time for care for a serious or complex condition that isn't available nearby. You have to ask. If your dependent traveled without you, you'll need to show you missed work or other activities because of it.

How to claim an exemption

Your state has to check what it already knows before asking you for anything: Medicaid claims from the last 12 months, SNAP and TANF records, jail records, and your application. Plenty of people will be excluded without lifting a finger. But don't count on it.

1. Answer the screening questions on your application or renewal honestly, especially about caregiving and health.
2. Tell your Medicaid office if something changes, like a new diagnosis, a pregnancy, or a new person you care for. You can do this online, by phone, by mail, or in person. An adult in your household or an authorized representative can do it for you.
3. Read every notice. By law, your state must tell you if it decides you're excluded or not. If it says you didn't meet the rule, the notice must explain how to show the rule doesn't apply to you. You get 30 days to respond, and you can ask for a fair hearing.
4. If you have a disability but don't fit an exemption, you can ask for a reasonable change in how the rule is applied to you. CMS reminds states they must make these under disability rights laws.

You can say: "I think I may be excluded from the work requirement because [reason]. What do you need from me to confirm that?"

What proof you may need

What your state asks for depends on the exemption and what it can already see. Starting January 1, 2028, states must ask for documents when they're reasonably available. But no state can deny you just because documents don't exist. It must accept other information instead.

Keep copies of anything you send, with the date.

Where Verified Hours fits

Verified Hours is for the other side of this: people who aren't exempt and need to prove volunteer hours. If that's you, or if your exemption ends, a signed monthly record from the place you volunteer is your best proof. Our guide to what counts as community service for Medicaid explains which hours count. You don't need any app to do it. A signed letter works.

If you think an exemption fits you, don't wait for your state to notice. Tell your Medicaid office now, keep a copy of what you said, and answer every notice within 30 days. If you're turned down, read our guide to what to do when your hours are rejected and ask about a hearing.